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2012 VGS submission to Knowle planning application sept12

This preceded the submission for the amended application:


Knowle, Station Rd, Sidmouth

Objection submitted by the Futures Forum of the Vision Group for Sidmouth, member of the Save Our Sidmouth campaign: 15th September 2012

We would urge Planning Officers at the District Council to reject this Outline Planning Application because it fails to take into account 1) popular and professional opinion, 2) the evidence 3) national and District policies, and 4) alternatives.


The NATIONAL PLANNING POLICY FRAMEWORK (NPPF) sets out 12 core land-use planning principles. Amongst these are: Being plan led, ‘…empowering local people to shape their surroundings’ (3.2 Para 17). However, the District Council has failed to ‘empower local people’ in the shaping of this Outline Planning Application, despite claims that ‘Consultation is underway and will continue as part of the viability assessment and planning processes for Knowle’ (Para 12: Is EDDC consulting with the Town Council, Chamber of Commerce and other local bodies?).

It is not the case that Davis Langdon, the ‘consultants preparing the economic impact assessment’, are ‘independent’; nor have they ‘made contact with’ Sidmouth Chamber of Commerce on an official and serious basis, let alone ‘other stakeholders’.

On the other hand it is the case that ‘Well attended public communication events were held during July 2012, with both individuals and organisations encouraged to formally respond to a questionnaire’: and yet the comments made by attendees details the overwhelming antipathy to the Outline Planning Application, which in turn has completely failed to take these public opinions into account: .

Not only is it unusual for an application of this size and controversy to fail to engage with ‘stakeholders’, but the NPPF makes it clear that ‘consultation’ should exceed the lacklustre single ‘meeting’ with the Town Council or reference to ‘local people’ taking the opportunity to ‘speak and ask questions’ and ‘listen to member discussion’: this level of engagement by no means entails ‘empowering local people to shape their surroundings’.

To cite but one professional opinion: In a press release on 31st August, the DEVON GARDENS TRUST objected formally to the outline planning application on several grounds:

1) ‘The parkland of The Knowle forms part of the attractive approach to Sidmouth, providing an important contribution to the overall historic character and landscape of the town. In this respect, the development proposed would have a significant detrimental effect upon the setting of this historic area and views into and out of it.’

2) The application proposes housing development on ‘areas which are an integral and important part of the existing and historic parkland.’ The Trust states that it is therefore ‘surprised’ that the District Council should be ‘proposing that this substantial area of the parkland should be developed’. Furthermore, the Trust ‘would have expected the Council to act in a responsible manner and protect the parkland from development’.


To cite but one piece of evidence proffered by the District Council: The ECONOMIC IMPACT ASSESSMENT OF THE KNOWLE RELOCATION PROJECT BY PETER BRETT ASSOCIATES contains innumerable errors of calculation and analysis.

1) The commuting costs for District Council employees (Page 11: Para 2.2.5) will in fact be considerable. This contradicts a central platform of the District Council’s calculations with regard to Housing and Employment land in the draft Local Plan.

2) The term ‘resilience’ has now become vacuous (Page 13: Para 2.3.3), just as ‘sustainability’ has lost all meaning. And yet the Report’s dismissal of the impact of loss of local contracts on small businesses (Page 14: Para 3.2.6) and the inaccuracies with regard to the expenditure of Sidmouthians (Page 18: Para 3.2.19, 21) indicate that there is little understanding of how a local economy can maintain its ‘resilience’, especially in these difficult times.

3) There are serious errors in the mathematics contained in this Assessment. For example, the understanding of ‘outlier’ in statistical terms is not correct (Page 17:  Para 3.2.18) and has led to distortions in the collection and analysis of data.

4) The failure of District Officers to take the issue of the park-and-walk facility seriously persists in this Assessment (Page 19:  Para 3.2.24; Page 20:  Para 3.2.24; Page 26:  Para 4.2.3; Page 31:  Para 4.3.6).

5) There are serious flaws in the calculations with regard to ‘employment creation’ (Page 21:  Para 3.3.5, 7; Page 24:  Para 3.4.2).

6) The drafting of the questionnaire to local businesses was so poor (Page 26:  Para 4.2.3; Page 28: Para 4.2.9; Page 30:  Para 4.3.2, 3, 6, 8, 9) that the information gathered and subsequent analysis cannot be taken seriously.


The Outline Planning Application should be refused because:

1) The District Council regards the Outline Planning Application as a Departure from the statutory DEVELOPMENT PLAN (DP) – as stipulated under the Town and Country Planning Act 1990 and the Planning and Compulsory Purchase Act 2004. The DP includes the current adopted East Devon Local Plan 2006-2011 (LP) – but not the emerging East Devon Local Plan, which is at an early stage and which cannot, therefore, be given any weight as a material consideration.

2) The Outline Planning Application contravenes the recently adopted NATIONAL PLANNING POLICY FRAMEWORK (NPPF) as a material consideration.

3) There are not sufficient other material considerations in favour of the Outline Planning Application to outweigh the provisions of the statutory DP.



There is no evidence to support the District Council’s contention that there is a local need for the scale and mix of Housing development or for the provision of a 60 bed Graduated Care Home – and as such the Outline Planning Application does not comply with LP POLICY S2 (Built Up Area Boundaries for Area Centres and Local Centres).

There is insufficient survey evidence to support the District Council’s contention that that wildlife will not be damaged, recreational land will not be lost and that highway safety will not be impaired – and as such  the Outline Planning Application does not meet the requirements of LP POLICY S4 (Development within Built-Up Area Boundaries).

Whereas the LP (Para 13.121) states that the Knowle is ‘land for Sport and Recreation’ and that ‘the Town has an overall undersupply of formal recreation land’, the PLANNING SUPPORT STATEMENT (2.28) contradicts this by stating that ‘even with a slight reduction in Open Space at the Knowle there will still be an ample supply of open space in Sidmouth’. There is no evidence to support either Bell Cornwell’s conclusions, or the District Council’s contention that the loss of Public Open Space (POS) is insignificant; furthermore, the Knowle and its parkland are not allocated for Housing in the District Council’s adopted LP but are, rather, designated as recreation land – and as such  the Outline Planning Application is contrary to LP POLICIES RE1/RE4 (Retention of Land for Sport and Recreation).

The development site is identified as Employment land and Public Open Space in the LP and not as Residential land; the POS is defined as greenfield site within an urban area – and as such  the Outline Planning Application contravenes LP POLICY H2 (Residential Land Allocation).

Whilst the District Council is to be commended in complying with LP POLICY H4 requiring a minimum of 40% affordable housing in any development of this scale due to the need for such provision in Sidmouth, because no viability or deliverability study has been undertaken by the District Council, as such the Outline Planning Application does not satisfy LP POLICY H4 (Affordable Housing).

The Outline Planning Application does not meet the criteria for exemption from LP POLICY E3 under which the District Council seeks to protect current Employment land provision. The District Council has not provided evidence of options for the retention of employment provision on the site or of a surplus supply of Employment Land in Sidmouth under the current LP – and as such the Outline Planning Application contravenes LP POLICYE3 (Retention of Employment Land).

There is insufficient survey evidence to support the District Council’s contention that that the habitat and foraging area of the roosting Lesser Horseshoe Bat population will not be lost or significantly damaged – and as such  the Outline Planning Application prejudices the protection afforded to the site by POLICY EN6 (Wildlife Habitats and Features).

Most significantly, should the Outline Planning Application be granted, it would be the first Housing application approved under the new draft LP policy, prior to the Public Examination and prior to Adoption of the draft LP next year – and as such the Outline Planning Application seriously undermines the integrity of the draft LP and should be rejected.


Paragraph 11 of the NPPF confirms the requirement that applications for planning permission be determined in accordance with the DP, unless material considerations indicate otherwise. Because insufficient material considerations have been evidenced, the Outline Planning Application is consequently not in accordance with the DP.

Neither heritage assets nor the natural environment will be conserved or enhanced (3.2 Para 17 and 3.6 Paras 128, 129, 131). An assessment has not been undertaken to indicate that POS and recreational buildings are surplus to requirement; there is no indication of how these would be replaced by equivalent or better provision (3.3 Para 74). Irreplaceable habitats (including the loss of aged or veteran trees) will be lost; there is no indication of how the development will outweigh the loss (3.4 Para 118).

Furthermore, NPPF Guidelines SN/SC/1096 stipulates that POS should not be built on.


The District Council cannot conclude that the Outline Planning Application will not have significant likely effects on European Protected Species, because the Ecological Survey provides no relevant information regarding the likely impact of the proposed development on bat foraging and flyways (DCW Survey Para 5.1.5). In the absence of a full ES and due regard to the requirements of the Habitats Directive (see Reg.9(5) of the Habitats Regulations 2012), the Outline Planning Application fails to satisfy the requirements of the Environmental Impact Assessment Regulations 2011 and the Conservation of Habitats and Species Regulations 2012.



The submission to the Local Plan consultation by the Sid Valley Energy Action Group (SVEAG) on 9th June 2012 pointed out that the last recorded DISPLAY ENERGY CERTIFICATE (DEC) (expired 30/09/2009) for the complete Knowle building (and not only the 1975 building) scored a creditable “C” rating on an A-G scale.  This expired on 30th September 2009, which begs the question as to why no further certification has been sought. To quote from the SVEAG submission: ‘Referring to the advisory report, if basic measures of insulation and energy efficiency awareness training are undertaken, together with other techniques of solar thermal and solar PV which make good economic sense, combined with a proper energy policy, there is no reason why the Knowle should not remain the home of EDDC for the benefit of employees, residents and the whole of Sidmouth!’

It is questionable that the consultants DAVIS LANGDON – taken on to provide an analysis of refurbishing the District Council premises at Knowle – are ‘independent’ as they have already been employed by the District Council to press ahead with the proposed relocation; in which case, any analysis of the viability of the present premises by the same consultancy cannot be regarded as ‘independent’. The District Council should allow a truly independent quotation to be undertaken – whereby a competent and recognised consultancy would gain access to the building in order to prepare a programme of refurbishment, based on an independent analysis of the current state of the building and of any proposals to ‘bring the building up to scratch’. There are several completely independent organisations which could deliver a cost benefit analysis of a potential refurbishment – including providing advice on environmental solutions to retrofit, such as energy saving measures and renewable energy technologies involving insulation, glazing, roofing, draft proofing, equipment and installations; there are also independent costings for data cabling, replacement electrics, smoke alarms and induction loops to be considered.

The District Council Leader referred to ‘HOT-DESKING’ during his interview with the BBC Spotlight programme on 4th September ( This measure would indeed save energy and building costs, as there would be less need for officespace – but this could apply just as easily to Knowle as to any other location.


Part of the argument for the new build at Honiton is due to lowering the carbon impact of the District Council’s current offices in Sidmouth. In which case, the question of what CARBON IMPACT ASSESSMENT has been made with regard to the construction of a new concrete-framed office building needs to be addressed. And yet there is no mention of this in the Davis Langdon report.  There is no possibility that the carbon impact of a new-build will represent a carbon saving, in the next few hundred years let alone in the next decades. In which case, a relocation should be seriously reconsidered. The analysis by Robin Fuller in his open letter to Councillors of 3rd  September (‘EDDC, flats, Councillors ’) makes it clear that: ‘The new building will take 50 years to repay its costs in carbon emissions from construction and a century to pay back the financial investment’.


Rather than demolishing the buildings at Knowle to finance the proposed relocation to Honiton, Robin Fuller  in his open letter to Councillors of 3rd September (‘EDDC, flats, Councillors ’) suggests ‘A TRULY GREEN ALTERNATIVE TO EDDC’S PROPOSAL’, which should be considered seriously by Planning Officers:

1) Modernise the 1975 building at Knowle through the sale of the Honiton Heathpark site; the District Council has publicly stated that it needs half of the current 9200 square metres of floorspace and that the current building is ‘not fit for purpose’; halving energy use together with state-of the-art eco-design would result in a truly ‘green’ office-space.

2) Sell the 1880/90s Knowle Hotel and caretaker’s lodge with outline planning permission to convert them into flats, which in turn would raise considerable sums for the District Council; this could well produce the 50 dwellings proposed in the draft LP and avoid the stated aim of building on green-field land; the substantial gardens and parkland would not be eaten into; and the park-and-walk facility would continue to serve visitors. As Mr Fuller states, the District Council ‘would be grossly irresponsible to move without properly costing this proposal first’.

Jeremy Woodward,

Secretary, Futures Forum, Vision Group for Sidmouth,

15th September 2012